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day notification period. These time periods were met
in this appeal.
IRC 6330(c) allows the taxpayer to raise any relevant
issue relating to the unpaid tax or the NFTL or Notice
of Intent to Levy at the hearing.
This Appeals Officer has had no prior involvement with
respect to these appealed liabilities.
2. Issues raised by the taxpayer;
Underlying liability or amount of liability
Taxpayer is disputing the tax liability. In cases
where the Department of Justice (DOJ) have previously
reduced a liability to judgment Appeals has no author-
ity to compromise a liability or reconsider the liabil-
ity issue which includes taxpayer’s challenge to the
collection statute of limitations. Further, Appeals
does not have the authority to consider any offer
involving the release of federal tax liens or withdraw-
als. Accordingly, since DOJ has previously reduced
this taxpayer’s liability to judgment, Appeals does not
have authority to consider the liability issue.
The underlying liability is sustained.
Collection Alternatives
Taxpayer did not propose any acceptable collection
alternatives. When the Notice of Federal Tax Lien was
filed it was appropriate. The liability was valid and
outstanding.
3. Balancing of need for efficient collection with
taxpayer concern that the collection action be no
more intrusive than necessary.
We believe the filing of the Notice of Federal Tax Lien
balances the need for efficient collection of taxes
with concerns that the collection action be no more
intrusive than necessary. [Reproduced literally.]
Petitioner filed a petition with the Court with respect to
the notice of determination. The petition contained statements,
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Last modified: May 25, 2011